TDEM warns improper procurement or missing records can make costs ineligible for DR‑4935 reimbursements

At the meeting, Reagan Middleton emphasized that applicants must document labor, equipment, materials, rentals, and contracts to support project worksheets and avoid ineligible costs. Required records include timesheets, pay‑policy documentation, equipment ownership proof, equipment‑use logs, invoices, purchase orders, and proof of payment.

"Improper procurement can lead to these costs being ineligible for reimbursement," Middleton said, stressing that tribal, local and private nonprofit applicants must comply with their own procurement procedures and applicable federal and state laws. He referenced required contract provisions in 2 C.F.R. and urged debarment verification using SAM.gov or state vendor hold lists.

Middleton also described emergency/exigency procurements: they are permitted when time is limited, but the applicant must document the reasons on letterhead for each procurement and ensure costs remain reasonable. He noted TDEM hosts monthly procurement trainings on Oct. 14, Nov. 12 and Dec. 9 to help local governments comply with federal procurement rules.